Dear Secretary Azar and Administrator Verma:
The Global Justice Center (“GJC”) submits this comment in response to the Department of Health and Human Services’ (“HHS”) Proposed Rule entitled Patient Protection and Affordable Care Act, Notice of Benefit and Payment Parameters for 2020 (the “Proposed Rule”). For purposes of this submission, commentary is limited to the portion of the Proposed Rule that would amend the Patient Protection and Affordable Care Act (“PPACA”) so that private insurance providers that provide abortion services would be required to offer a version of the plan which does not cover abortion services.
GJC is an international human rights organization based in New York dedicated to achieving gender equality through the rule of law. For the past decade, GJC has been at the forefront of efforts to ensure that the law protects and promotes access to comprehensive sexual and reproductive health rights for women and girls around the world. As experts in women’s rights and human rights, we write to express our vehement opposition to the Proposed Rule.